2 Case 3:13-cv HU Document 40 Filed 04/19/13 Page 2 of 5 Page ID#: 524 I, Adrienne Gemperle, certify and declare as follows: 1. I am currently employed by Starbucks Corporation ("Starbucks") as a partner resources vice president for the division encompassing Oregon. I am familiar with and have personal knowledge of the employment records maintained regarding Star bucks employees. I submit this declaration in support of Defendant Starbucks Corporation's Opposition to Plaintiffs' Motion for Remand. 2. In the regular course of business, Starbucks maintains electronic human resources and payroll databases containing information regarding the employment status, job positions, termination dates, and wages of its current and former employees, including employees in Oregon. I am familiar with these databases and regularly rely on the data they maintain in connection with my job responsibilities. 3. On December 16, 2012, Star bucks conducted queries of these databases to support its Notice of Removal in the above titled action. Queries of these databases revealed the following: 4. Between December 10, 2009 and the date ofthe queries, Starbucks employed approximately 6,028 individuals as baristas or shift supervisors in Oregon. 5. For 3,335 of the individuals identified in paragraph 4, above, the employment with Starbucks ended after December 10, On average, the 3,335 individuals identified in paragraph 5, above, earned an hourly wage of approximately $9.77 at the time their employment ended. 7. On February 3, 2013, Starbucks again queried its human resources and payroll databases, in response to demands by plaintiffs' counsel in this matter for data relevant to Starbucks Notice of Removal. Using these queries, Starbucks compiled a spreadsheet titled "Oregon Partners With Imputed Tips: December 10,2009- December 21, 2012." (Starbucks refers to its employees as "partners.") The spreadsheet identified each partner in the list by his or Page 2 - DECLARATION OF ADRIENNE GEMPERLE ISO OPPOSITION TO MOTION FOR REMAND DWT vi (503) main (503) fax

3 Case 3:13-cv HU Document 40 Filed 04/19/13 Page 3 of 5 Page ID#: 525 her unique partner number, and listed the separation date and hourly rate of pay for each partner who separated from employment on or before December 21, Like the December 16 queries, the February 3 queries identified 6,028 partners who worked as baristas or shift supervisors in Oregon stores between December 10, 2012 and December 21, 2012, but they also revealed that 107 of these individuals never received imputed tips during that time period. These 107 individuals were excluded from the spreadsheet, leaving 5,921 individuals in the spreadsheet. 9. The spreadsheet identifies 3,258 former partners, 77 fewer than stated in Starbucks Notice of Removal. This discrepancy is explained by the exclusion of partners who received no imputed tips during the relevant time period, and by the fact that the queries that created the spreadsheet were conducted almost two months after the queries that were used to support the Notice of Removal. 10. The February 3 queries identified 3,353 baristas and shift supervisors who separated from employment between December 10,2009 and December 21, more than identified by the December 16 queries. This difference is explained primarily by the fact that 19 ofthese separations were entered into Starbucks databases after December 16, Additionally, one separation which was captured in the December 16 queries was excluded by the February 3 queries, because the effective date of that separation was December 25, 2012, and the February 3 queries only included separations that were effective as of December 21, Of the 3,353 separated partners identified by the February 3 queries, 96 never received imputed tips. Therefore, these partners were excluded from the spreadsheet, as described above in paragraph 8, leaving 3,258 separated partners in the spreadsheet. 12. The spreadsheet lists 30 partners with final rates of pay below the prevailing Oregon minimum wage as of the date of their separation. This apparent discrepancy is also easily explained. Page 3 -DECLARATION OF ADRIENNE GEMPERLE ISO OPPOSITION TO MOTION FOR REMAND DWT vi

4 Case 3:13-cv HU Document 40 Filed 04/19/13 Page 4 of 5 Page ID#: Twenty-eight of the partners indentified in paragraph 12 worked as baristas or shift supervisors in Oregon during the relevant time period, but were working for Starbucks in a different state when they separated from employment. Thus, the spreadsheet lists their pay rate upon the termination of their employment in a state other than Oregon. 14. One partner identified in paragraph 12 separated from employment effective January 1, 2011, but last worked hours for Starbucks on December 30,2010. This partner's hourly rate was $8.40 in 2010, which was also Oregon's minimum wage that year. 15. One partner identified in paragraph 12 is listed in the spreadsheet with an hourly rate of$7.75. This partner was hired in Utah on June 16, 2010 at that hourly rate. The partner transferred to Oregon on September 27,2010, but separated from employment six days later. 16. Starbucks records reflect that Hannah Fredrickson, Ashley Krening and Maurialee Bracke are no longer employed by Starbucks. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed on this 2- <I' day of March, 2013, in Seattle, Washington. ~t:p7 "'- ~v ~ ADRIENNE GEMP RL Page 4 -DECLARATION OF ADRIENNE GEMPERLE ISO OPPOSITION TO MOTION FOR REMAND DWT v

Received 09/02/2015 Commonwealth Court of Pennsylvania Filed 09/02/2015 Commonwealth Court of Pennsylvania 1 REL 2001 IN THE COMMONWEALTH COURT OF PENNSYLVANIA IN RE: Reliance Insurance Company In Liquidation

SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE SELF-HELP CENTER www.occourts.org ANSWERING A PERSONAL INJURY, PROPERTY DAMAGE OR WRONGFUL DEATH COMPLAINT All documents must be typed or printed neatly. Please

Case 1:13-cv-00105-GBL-TRJ Document 54 Filed 03/10/14 Page 1 of 5 PageID# 318 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA ALEXANDRIA DIVISION THE TRIZETTO GROUP, INC. Plaintiff,

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA Richmond Division INFORMATION ON REPRESENTING YOURSELF (PRO SE) IN A CIVIL ACTION INTRODUCTION The following instructions have been compiled to

Revised: August Federal Pro Se Clinic CENTRAL DISTRICT OF CALIFORNIA Entering Default against Defendants When a properly served defendant fails to appear in a lawsuit on time, the plaintiff may request

Case 1:13-cv-01300-MSK-MJW Document 89 Filed 10/24/13 USDC Colorado Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 13-cv-01300-MSK-MJW JOHN B. COOKE, Sheriff

Document Page 1 of 6 UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW JERSEY Caption in compliance with D.N.J. LBR 9004-2(c) FOX ROTHSCHILD LLP (Formed in the Commonwealth of Pennsylvania) Michael J. Viscount,

IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR THE COUNTY OF MULTNOMAH 1 EMMETT ROCCO PARMAN, a Minor Child; JEANA MARIE FRAZZINI; and KRISTAN DENE PARMAN, v. Plaintiffs, STATE OF OREGON; THEODORE KULONGOSKI,

July 7, 2015 01:37 PM IN THE COURT OF APPEALS OF THE STATE OF OREGON OLIVIA CHERNAIK, a minor and resident of Lane County, Oregon; LISA CHERNAIK, guardian of Olivia Chernaik; KELSEY CASCADIA ROSE JULIANA,

Case 5:03-cv-02182-JRA Document 180 Filed 07/29/2008 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION IN RE THE GOODYEAR TIRE & RUBBER COMPANY ERISA LITIGATION

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT CHATTANOOGA UNITED STATES OF AMERICA, ex rel. GLENDA MARTIN, Civil Action No. 1:08-CV-251 Plaintiffs, MATTICE/CARTER v. LIFE CARE CENTERS OF

Hartford Casualty Insurance Company v. Peanut Corporation Of America Doc. 5 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA LYNCHBURG DIVISION HARTFORD CASUALTY INSURANCE COMPANY,

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND ATTORNEY ADMISSION INFORMATION A. FEES Application for Admission.................................. $ 200.00 Application for Renewal....................................

Case: 1:13-cv-00903-SSB-SKB Doc #: 9 Filed: 03/11/14 Page: 1 of 5 PAGEID #: 31 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT CINCINNATI THOMAS E. PEREZ, Secretary

PUBLIC UNITED STATES OF AMERICA BEFORE THE FEDERAL TRADE COMMISSION In the Matter of RAMBUS INC., Docket No. 9302 a corporation. DECLARATION OF STEVEN M. PERRY IN OPPOSITION TO MOTION OF NON-PARTY MITSUBISHI

Case 108-cv-05722-LTS-DCF Document 264 Filed 09/04/15 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK IN RE AMERICAN INTERNATIONAL GROUP, INC. ERISA LITIGATION II This Document

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION Case No. 5:14-cv-00369-BO FELICITY M. TODD VEASEY and SECOND AMENDMENT FOUNDATION, INC., Plaintiffs, BRINDELL

Case 3:10-cv-00188-HEH Document 87 Filed 08/16/10 Page 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division COMMONWEALTH OF VIRGINIA, ex rel. Kenneth T. Cuccinelli,

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORID A ORLANDO DIVISION In re CNL HOTELS & RESORTS, INC. I Case No. 6 :04-cv-1231-Orl-31KRS Securities Litigation (Consolidated with 6:04-cv-1341-Orl-19JGG)

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA PARKER, et al. Plaintiffs v. NO. 1:03CV00213(EGS DISTRICT OF COLUMBIA, et al. Defendants MOTION TO CONSOLIDATE COME NOW Plaintiffs in Seegers,

PRO SE OFFICE UNITED STATES DISTRICT COURT DANIEL PATRICK MOYNIHAN UNITED STATES COURTHOUSE 500 PEARL STREET, ROOM 230 NEW YORK, NEW YORK 10007 Ruby J. Krajick CLERK OF COURT HOW TO FILE AN ANSWER An answer

Case 5:11-cv-00360-OLG-JES-XR Document 1312 Filed 05/13/15 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION SHANNON PEREZ, et al., Plaintiffs, v. CIVIL

Case:11-01634-HRT Doc#:135 Filed:07/06/15 Entered:07/06/15 13:35:01 Page1 of 5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF COLORADO In re: THE BANNING LEWIS RANCH COMPANY LLC, et al., 1 Debtors.

Case 1:15-cv-01156-LMM Document 34 Filed 06/29/16 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Steven L. Markos, Tiffany Davis, and Gregory Page,

Case 3:01-cv-01275-HLA-HTS Document 315 Filed 10/04/07 Page 1 of 11 PageID 3757 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION AMERICAN ASSOCIATION OF PEOPLE WITH DISABILITIES;

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF KANSAS In re: ) ) LARRY RAY BEESON, ) Case No. 01-42214 ) Chapter 13 Debtor. ) ) ORDER GRANTING TRUSTEE S MOTION TO ALTER OR AMEND ORDER OF DECEMBER

APPLICATION FOR SPECIAL ADMISSION UNDER RULE 14-804 SPECIAL ADMISSION EXCEPTION FOR MILITARY LAWYERS To apply for special admission under Rule 14-804, please send a complete application along with an application

4:08-cv-02753-JMC -TER Date Filed 04/20/11 Entry Number 184 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION HOWARD K. STERN, as Executor of the Estate

3:14-cv-00300-JFA Date Filed 07/31/14 Entry Number 80 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA COLUMBIA DIVISION Kaleigh R. Dittus, Courtney A. Snyder, ) Civil

CAVEAT: This sample is provided to demonstrate style and format. It is not intended as a model for the substantive argument, and therefore counsel should not rely on its legal content which may include

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK \ - In the matter of the application of THE BANK OF NEW YORK MELLON (as Trustee under various Pooling and Servicing Agreements and Indenture Trustee

UNITED STATES OF AMERICA BEFORE THE FEDERAL TRADE COMMISSION 04 23 2012 In the Matter of PUBLIC DOCUMENT MCWANE, INC., a corporation, and Docket No.: 9351 STAR PIPE PRODUCTS, LTD., a limited partnership.